INTRODUCTION -
Registered investment advisers to private funds clients are required to make filings with the Securities and Exchange Commission (SEC) each year and deliver certain information to their clients. In...more
Commodity Futures Trading Commission (CFTC) Regulation 3.10(c)(3) currently provides an exemption from registration for non-U.S. commodity pool operators (CPOs) and commodity trading advisors (CTAs), if they solely operate...more
- A CPO will be prohibited from claiming an exemption from registration under CFTC Regulation 4.13 if it or any of its principals has in their backgrounds a statutory disqualification under the Commodity Exchange Act.
- A...more
6/12/2020
/ Bad Actors ,
Certification Requirements ,
CFTC ,
Commodity Exchange Act (CEA) ,
Commodity Pool ,
CPOs ,
Exemptions ,
Final Rules ,
Investment Management ,
National Futures Association ,
Registration Requirement ,
Securities and Exchange Commission (SEC)
Commodity Futures Trading Commission (CFTC) Regulation 3.10(c)(3) currently provides that non-U.S. commodity pool operators (CPOs) are exempt from registration if they solely operate non-U.S. commodity pools offered to...more
• Effective January 1, 2020, clarifying amendments to rules regarding communications with the public and use of promotional material will go into effect.
• Effective February 1, 2020, CTA will be subject to new limitations...more
12/27/2019
/ Amended Rules ,
Asset Management ,
Brokers ,
Business Development Companies ,
CFTC ,
Commodity Pool ,
Commodity Trading Advisors (CTAs) ,
Compliance ,
CPOs ,
Electronic Communications ,
Exemptions ,
Family Offices ,
Investment Adviser ,
Investment Companies ,
Investment Management ,
NFA ,
Offshore Funds ,
Registration Requirement ,
Reporting Requirements ,
Securities and Exchange Commission (SEC)
• The NFA has determined that registered CPOs must implement an internal controls system and highlighted best practices for such a framework.
• In response to certain frequently asked questions, the NFA has also updated its...more
1/15/2019
/ Best Practices ,
Books & Records ,
CFTC ,
Commodity Pool ,
Consumer Fraud ,
CPOs ,
Cyber Attacks ,
Cyber Incident Reporting ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Data Security ,
Employee Monitoring ,
Employee Training ,
Financial Services Industry ,
Guidance Update ,
Information Security ,
Information Systems Security Program (ISSP) ,
Internal Controls ,
Investment Management ,
NFA ,
Notification Requirements ,
Policies and Procedures ,
Popular ,
Recordkeeping Requirements ,
Risk Assessment
The staff of the Commodity Futures Trading Commission (CFTC) yesterday changed its position and no longer requires a no-action request for delegation of commodity pool operator (CPO) functions from persons that might...more